Holden Ex Rel. Estate of Holden v. Holden Ex Rel. Fulmer

ANDERSON, Judge

(dissenting):

I respectfully dissent. I disagree with the analysis and reasoning of the majority. I would affirm.

ISSUE

Did the Circuit Court err in finding Sons’ disclaimers to their father’s estate were ineffective and that Sons retained their interests in the estate?

LAW/ANALYSIS

The guardian ad litem for the grandchildren contends the Circuit Court erred in finding Sons’ disclaimers were invalid. I disagree.

To disclaim an interest in property, a disclaimant is required to comply with the statutory scheme set forth by the South Carolina General Assembly. Pate v. Ford, 297 S.C. 294, 376 S.E.2d 775 (1989) (discussing the predecessor statute to § 62-2-801); In re Will of Hall, 318 S.C. 188, 456 S.E.2d 439 (Ct.App.1995). The declared intent of the South Carolina General Assembly in enacting the statutory scheme for disclaimers was “to clarify the laws of this State with respect to the subject matter hereof in order to ensure the ability of persons to disclaim interests in property without the imposition of federal and state estate, inheritance, gift, and transfer taxes. This provision is to be interpreted and construed in accordance with, and in furtherance of, that intent.” S.C.Code Ann. § 62-2-801(f) (1987).

The South Carolina Probate Code’s disclaimer statute provides a person may disclaim an inheritance as follows:

In addition to any methods available under existing law, statutory or otherwise, if a person ..., as a disclaimant, makes a disclaimer as defined in § 12-16-1910 of the 1976 Code, with respect to any transferor’s transfer (including transfers by ... intestacy ...) to him of any interest in ... *464property, ... the interest ... is considered never to have been transferred to the disclaimant.

S.C.Code Ann. § 62-2-801(a) (Supp.1998).

Section 12-16-1910, referenced above, deals with the effect of a disclaimer of a property interest for purposes of estate taxes. This section states “if a person as defined in Section 62-2-801 [the disclaimer statute] makes a disclaimer as provided in Internal Revenue Code Section 2518 with respect to any interest in property, this chapter applies as if the interest had never been transferred to the person.” S.C.Code Ann. § 12-16-1910 (Supp.1998). Section 2518 of the Internal Revenue Code, concerning estate and gift taxes, defines a “qualified disclaimer” for purposes of federal tax laws as follows:

(a) General rule. — For purposes of this subtitle, if a person makes a qualified disclaimer with respect to any interest in property, this subtitle shall apply with respect to such interest as if the interest had never been transferred to such person.
(b) Qualified disclaimer defined. — For purposes of subsection (a), the term “qualified disclaimer” means an irrevocable and unqualified refusal by a person to accept an interest in property but only if—
(1) such refusal is in writing,
(2) such writing is received by the transferor of the interest, his legal representative, or the holder of the legal title to the property to which the interest relates not later than the date which is 9 months after the later of—
(A) the day on which the transfer creating the interest in such person is made, or
(B) the day on which such person attains 21,
(3) such person has not accepted the interest or any of its benefits, and
(4) as a result of such refusal, the interest passes without any direction on the part of the person making the disclaimer and passes either—
(A) to the spouse of the decedent, or
*465(B) to a person other than the person making the disclaimer.

26 U.S.C.A. § 2518 (1994).

The United States Treasury Department has interpreted the Internal Revenue Code’s requirement in § 2518(b)(4) that the disclaimed interest pass “without any direction” on the part of the disclaimant. The Department explained:

(e) Passage without direction by the disclaimant of beneficial enjoyment of disclaimed interest — (1) In general. A disclaimer is not a qualified disclaimer unless the disclaimed interest passes without any direction on the part of the disclaimant to a person other than the disclaimant.... If there is an express or implied agreement that the disclaimed interest in property is to be given or bequeathed to a person specified by the disclaimant, the disclaimant shall be treated as directing the transfer of the property interest.

Treas.Reg. § 25.2518-2(e)(l) (1997).

Sons and Mrs. Holden testified at the Probate Court hearing it was their agreement that the property was to pass to Mrs. Holden. Further, this agreement is expressly stated in the cover letter that accompanied the filing of the disclaimers.

The guardian asserts on appeal that parol evidence was not admissible to vary the legal effect of the disclaimers. However, the guardian did not object in a Rule 59, SCRCP, motion to the Circuit Court’s use of parol evidence in its decision. This argument, therefore, is not preserved. See Talley v. South Carolina Higher Educ. Tuition Grants Comm., 289 S.C. 483, 347 S.E.2d 99 (1986) (issue may not be raised for first time on appeal); United Dominion Realty Trust, Inc. v. Wal-Mart Stores, Inc., 307 S.C. 102, 413 S.E.2d 866 (Ct.App.1992) (where Circuit Court sitting on appeal did not address an issue and party made no motion pursuant to Rule 59(e), SCRCP, to have it rule on the issue, the allegation was not preserved for further review by Court of Appeals). This Court should consider the same evidence the Circuit Court used in evaluating whether that court erred. Further, according to Treasury Regulation § 25.2518-2(e)(l), either an express or an implied agreement may be considered “direction” by the disclaimant. An implied agreement may be evidenced only by parol evidence.

*466I find that an express and an implied agreement existed for Sons to give their interests to their mother. Under the Treasury Regulation, Sons are treated as having directed their interests to their mother. Accordingly, the Circuit Court correctly held Sons’ disclaimers were not “qualified disclaimers” and are, therefore, ineffective to transfer property pursuant to South Carolina’s disclaimer statutory scheme. The attempted disclaimers are void. Consequently, Sons retain their intestate interests in their father’s estate.

CONCLUSION

I agree with the Circuit Court’s determination that Sons’ disclaimers were invalid because they failed to meet the requirements of a “qualified disclaimer” under the Internal Revenue Code by attempting to direct the disposition of the property, and they were, therefore, invalid under state law. Consequently, Sons retain their interests in their father’s estate. I would affirm the decision of the Circuit Court.